What Is a Request for Production?

A request for production is part of the discovery process in a lawsuit. It’s a formal written request that one party sends to another, asking for documents, records, or files that contain necessary information about the case.

These could include:

• Contracts
• Emails
• Reports
• Financial statements
• Any materials that help clarify the facts in dispute

The goal of an RFP is to make sure both sides have access to the same information before going to court. This makes sense because it allows each party to prepare its arguments based on complete and accurate evidence.

When a law firm receives an RFP, it reviews each request carefully, gathers the relevant materials, and decides which documents can be shared. Privileged or confidential data must be reviewed and redacted before being produced.

Managing this process manually takes time and increases the chance of missing important files. To handle it more efficiently, many firms use RFP automation tools that organize, tag, and produce documents automatically.

This saves hours of work and gives both the firm and the client confidence that every request has been handled correctly and consistently throughout the discovery process.

What Makes a Strong RFP Response

A strong RFP response depends on the case, the client, and the type of legal documents requested. But usually, here’s what makes an RFP response clear, defensible, and useful to both sides.

• Complete and accurate: It includes all the information requested, organized by request number and supported with clear references or exhibits.
• Concise and focused: The response avoids unnecessary detail and keeps the language direct. Each answer should make sense without long explanations.
• Well-structured: Every response lists the request first, followed by the reply. This helps readers follow the document easily.
• Relevant and precise: The response focuses only on materials related to the request and avoids mixing unrelated topics.
• Transparent: When documents are withheld or redacted, the reason is clearly stated. This helps demonstrate fairness in the discovery process.
• Professional tone: Even when objecting, the wording stays neutral and polite.

Sometimes, it’s also helpful to include additional information that clarifies how the data was collected or reviewed.

Overall, a good RFP response should demonstrate that the producing party handled the process carefully and in good faith. This shows both preparation and respect for the opposing side’s right to review evidence.

RFP Response Examples

These examples show how law firms usually structure their replies to different types of requests for production. They’re based on common discovery situations and demonstrate how to stay professional, clear, and compliant with court rules.

Each example reflects a different scenario:

Full Compliance Response

Request No. 1:

Produce all contracts signed between Plaintiff and Defendant from January 2021 through December 2023.

Response:

Defendant will produce all responsive documents. The legal team reviewed every contract within the requested time frame, confirmed that each document is accurate and complete, and attached the full set as Exhibit A.

No documents are being withheld. All materials were collected directly from the client’s files and verified before submission.

This example shows a thorough, direct reply written in active voice. It explains what actions the team took (reviewing, confirming, and attaching) and makes it clear that production is complete.

The language is confident, transparent, and easy to read, which helps maintain credibility during discovery.

Partial Compliance Response

Request No. 2:

Produce all internal emails between company executives regarding the product recall from 2020 to 2023.

Response:

Defendant objects to this request as overly broad and not limited in scope or time. After review, the legal team identified relevant communications concerning the Model X recall between March and August 2023.

Defendant will produce those emails as Exhibit B. All unrelated or privileged communications have been withheld.

This one shows how to comply in part while keeping the response reasonable. It demonstrates that the team reviewed the request, narrowed the focus, and provided only what was relevant.

Plus, the wording stays factual and professional, which acknowledges the discovery objection but still shows cooperation and good faith in the production process.

Objection Due to Scope or Relevance

Request No. 3:

Produce all employee performance evaluations from 2018 to 2024.

Response:

Defendant objects to this request on the grounds that it seeks irrelevant and confidential information not related to the issues in dispute. The request also lacks reasonable limits in time and subject matter. No documents will be produced in response.

This response shows a clear and professional objection. It explains the reason for refusing production (irrelevance and confidentiality) without unnecessary language. The response stays direct and avoids emotional or defensive wording.

A well-written objection like this helps protect client data while keeping the tone neutral and respectful, which can make future negotiations or revisions to the request smoother.

Clarification or Request for Narrower Terms

Request No. 4:

Produce all documents related to communications with third-party vendors.

Response:

Defendant objects to this request as vague and overly broad. It is unclear which vendors or time period the request covers.

Defendant requests clarification or a narrower scope limited to specific vendors and relevant projects. Once clarified, Defendant will review and produce responsive documents.

This type of response shows professionalism while maintaining control of the discovery process. It acknowledges the request, identifies the pain points, and invites clarification instead of rejecting the RFP issuer outright.

That approach demonstrates cooperation and helps avoid unnecessary disputes about scope or interpretation later in the case.

Extension or Need for Additional Time

Request No. 5:

Produce all reports and internal communications concerning the termination of the joint venture.

Response:

Defendant has begun collecting and reviewing the requested materials but requires additional time to complete the process. The legal team expects to finish review and production within 14 days.

Defendant will notify Plaintiff immediately once the responsive documents are ready for delivery.

This example reflects a practical and honest update. It shows that the responding party is taking action, managing the workload responsibly, and keeping communication open.

Formatting and Best Practices

A well-organized response makes the legal drafting process smoother and helps both sides review materials without confusion. Consistency across documents is key, especially when handling multiple RFPs in one case.

A clear format also reduces errors and gives the court more insight into how the documents were collected and reviewed.

Here are a few best practices for creating an effective RFP response:

• Use a clear structure: List each request, followed by its response. Keep numbering consistent throughout the entire process.
• Keep tone and language professional: Avoid unnecessary explanations or defensive language.
• Reference exhibits properly: Link each response to exhibits or attachments when relevant.
• Include an RFP cover letter: Summarize what’s being produced, note any objections, and provide contact details for follow-up.
• Work from a standard template: Templates save time, help maintain accuracy, and make future RFPs easier to manage.

Automation tools like AutoDoc make this far simpler. AutoDoc auto-drafts every RFP, cites exact Bates pages, and packages the finished response with its production, ready for review in seconds. In other words, it replaces weeks of manual review with one upload.

If you’d like to end repetitive discovery work, join the AutoDoc waitlist for early access and see how it can handle your next round of RFPs in just 3–10 seconds per request.

Automating RFP Responses

RFP response software helps legal teams create accurate responses to requests for production without spending hours on manual review.

It takes over the repetitive parts of the job, like collecting files, applying Bates numbers, formatting discovery responses, and organizing attachments. With those tasks out of the way, your team can focus on higher-level work.

If you’ve ever managed discovery manually, you know how time-consuming it can be to search through folders, rename files, and double-check references.

Automation replaces those steps with a structured system that identifies responsive documents, fills in response templates, and keeps everything consistent across cases.

Here’s what automated RFP tools often handle:

• Auto-draft responses: Build complete answers from uploaded files or data sources.
• Apply Bates numbers automatically: Assign clear page identifiers in seconds.
• Locate responsive materials: Detect and attach relevant files to each request.
• Support collaboration: Allow attorneys, paralegals, and other team members to review and edit in one shared workspace.

Automation lets your team spend less time on administrative work and more time supporting clients and refining case strategies.

It also keeps a reliable record of each action taken, so that every RFP response stays organized, consistent, and defensible throughout the discovery process.

End Repetitive RFP Work With Briefpoint Autodoc

Each RFP is different, but the goal stays the same: produce complete, accurate, and defensible responses without wasting days on formatting and document review. That’s where Briefpoint helps you work smarter.

With Briefpoint, you can propound and respond to RFPs, RFAs, and interrogatories across every U.S. state and federal district in just a few clicks.

Upload a discovery request, review AI-assisted objections, and export a formatted response ready to serve. It’s designed for real legal workflows that should be fast, defensible, and fully editable.

For teams managing heavy discovery workloads, Briefpoint eliminates the slow parts of the process. You’ll draft high-quality responses that match your firm’s preferred language, maintain compliance with local court rules, and keep every matter organized from start to finish.

Ready to see how it all works? Book a demo with Briefpoint today.

1. Define a Clear eDiscovery Strategy and Protocol

A clear eDiscovery strategy gives legal teams a structured approach throughout the entire process. It promotes consistency, reduces confusion, and keeps deadlines on track.

The plan should align with the Electronic Discovery Reference Model (EDRM), which outlines the following stages: identification, preservation, collection, processing, review, and production.

When creating your strategy, remember to:

• Set clear goals for scope, timelines, and team roles.
• Document every step to maintain transparency and defensibility.
• Use standard templates for data requests and productions.
• Define escalation points for handling disputes or technical issues.
• Update the plan regularly as laws, lawyer tools, and data sources change.

A written eDiscovery protocol forms the backbone of every matter. It should describe how data will be preserved, how privilege will be protected, and what file formats will be used for production.

This structure keeps everyone aligned from the start and helps prevent missing data or inconsistent handling later.

2. Involve Legal, IT, and Compliance Teams Early

Legal, IT, and compliance teams each play a unique role in managing electronically stored information (ESI), and early coordination prevents confusion later. When these teams work together from the start, identifying relevant data becomes faster and more accurate.

For example, when litigation is anticipated, the legal team defines the scope of discovery and which custodians may hold relevant ESI.

The IT department then identifies where that data lives (perhaps across cloud storage platforms, email servers, or internal systems) while compliance reviews the process to confirm it aligns with privacy and retention policies.

If these groups don’t align early, data could be lost, duplicated, or mishandled, putting the organization at risk of sanctions or missed deadlines.

Many organizations now rely on eDiscovery tools that let cross-functional teams collaborate in real time, centralizing case data and tracking progress from preservation to production.

A shared platform improves communication, reduces manual work, and keeps every department accountable.

For teams seeking a simpler, faster, and more reliable approach to document preparation during discovery, Briefpoint offers automation that turns complex requests into accurate, court-ready documents in minutes. 

Book a demo today.

3. Identify and Preserve Data Sources Promptly

Quick identification and preservation of electronic data are key steps in the discovery process.

Once litigation is expected, legal teams must act fast to locate and secure relevant data before it’s altered or deleted. Delays can lead to spoliation or incomplete productions, both of which can harm a case.

The first step is mapping data sources, which means creating a clear record of where information is stored and who controls it. Common data sources include:

• Company email systems and archives
• Shared drives and document management tools
• Cloud storage platforms like Google Drive, OneDrive, or Dropbox
• Messaging apps such as Slack or Microsoft Teams
• Employee laptops, phones, or external devices
• Social media posts

Once these sources are identified, data collection should begin under defensible procedures that maintain metadata and prevent modification. Preservation notices must also be issued to custodians responsible for the data, suspending any auto-deletion or retention policies.

Plus, documenting each step of data preservation builds credibility and protects against challenges later in court. A consistent, repeatable approach keeps the process transparent and helps the team handle future matters more efficiently.

4. Use Legal Hold Procedures Effectively

A well-managed legal hold process is one of the most important parts of data preservation during discovery.

When a dispute or investigation is anticipated, legal professionals must suspend routine data deletion policies and preserve all potentially relevant ESI. This step prevents the loss of key evidence and demonstrates good faith compliance with the court.

A legal hold begins with a clear notice sent to custodians. Employees or departments likely to have relevant documents or electronic records. The notice explains what data must be preserved, how it should be handled, and who to contact with questions.

For instance, if a company expects litigation involving employment issues, HR staff and managers may receive a hold instructing them not to delete emails, reports, or internal chat messages tied to the event in question.

Tracking acknowledgments and sending reminders are equally important. Every action, from issuing the notice to releasing the hold, should be logged for transparency.

Many legal teams now use automated legal hold software to monitor compliance and record each step. This level of documentation protects the organization and confirms that data was preserved properly if the process is ever questioned in court.

5. Collect Data in a Defensible and Documented Way

Once a legal hold is in place and data preservation is confirmed, the next phase of the discovery process involves collecting that data for review. This transition is critical because any misstep during collection can damage file integrity or cast doubt on the evidence.

Moreover, data collection is one of the most sensitive parts of legal discovery, and every action must be defensible if challenged in court.

Legal teams should apply consistent procedures that maintain authenticity and retain relevant information exactly as it existed. This includes preserving metadata, timestamps, and detailed records of each activity.

Defensible collection often involves coordination between legal and IT teams. Data must be copied from secure data storage systems using approved forensic tools that prevent alteration.

For example, when collecting data from mobile devices, specialists may extract text messages or attachments in a controlled environment to preserve their original state.

A simple collection record may include:

• The person responsible for the collection and the date completed
• The tools or software used
• The source systems, such as email servers or cloud databases

Documenting every action supports strong information governance and demonstrates accountability. In large legal proceedings, complete records protect the organization from disputes about data handling and show that the collection followed a defensible process.

6. Leverage Advanced Search and Filtering Tools

Advanced search and filtering tools are core features of any modern eDiscovery platform. They allow legal teams to narrow large sets of data into smaller, more focused collections that matter to the case.

As data volumes continue to grow across emails, chat logs, and cloud solutions, these tools make it possible to manage the document review stage with precision and speed.

In the modern litigation process, the biggest eDiscovery challenges often involve identifying what’s relevant among thousands or even millions of files.

Keyword searches, date filters, and metadata queries help locate information quickly, while advanced analytics can detect duplicate files or similar content that might otherwise be reviewed multiple times.

Some systems also let users analyze log files or communication patterns to uncover hidden connections between custodians or data sources.

A strong review process combines these tools with attorney oversight to confirm accuracy and context. Automation alone can’t replace legal judgment, but it can remove the manual burden of sorting irrelevant material.

7. Apply Technology-Assisted Review or AI for Efficiency

Technology-assisted review (TAR) and AI-powered review systems have become standard in modern eDiscovery because they help manage the overwhelming amount of digital data generated in litigation.

Essentially, these technologies speed up the review of emails, documents, and messages while maintaining accuracy and consistency in how relevance and privilege are determined.

• Technology-assisted review: Uses machine learning and predictive coding to identify patterns in previously reviewed data, which allows the system to rank remaining documents by likelihood of relevance.
• Artificial intelligence: Expands on TAR by applying natural language processing and contextual analysis to understand meaning, not just keywords, across large datasets.

In practical terms, TAR and legal AI tools learn from attorney input and apply those lessons to new files, which helps teams prioritize what to review first. This reduces manual workload and accelerates the production of electronically stored information.

When used responsibly, TAR can cut review time by more than half and improve consistency in identifying data produced for disclosure. Combined with human oversight, these tools help legal teams meet discovery deadlines efficiently while keeping the process defensible.

8. Maintain Strong Chain-of-Custody Documentation

A clear chain of custody makes sure that every piece of evidence collected during eDiscovery can be trusted.

More specifically, it records how data moves from collection to review and production, showing that nothing was changed, lost, or mishandled. Strong documentation also supports regulatory compliance, especially in industries where audit trails are required.

To keep all teams on the same page, every handoff should be recorded in a chain-of-custody log. This log tracks:

• The names of key custodians involved in handling or accessing data
• The date and time of each transfer
• The storage location and transfer method used
• Verification notes confirming file integrity

For example, if an outside vendor receives a set of emails for review, the record should show when the transfer occurred, who approved it, and how the files were verified before upload. Each action must be timestamped and supported by documentation.

Maintaining this level of tracking not only protects against disputes but also helps in ensuring compliance with legal discovery standards. Courts expect transparency in how evidence is handled, and a reliable chain of custody provides exactly that.

9. Review and Redact Sensitive Information Carefully

During the review phase of eDiscovery, handling confidential data requires both precision and awareness of privacy laws and eDiscovery rules.

Legal teams must identify and redact sensitive content before further processing or production to avoid exposing personal or privileged material. Failure to do so can lead to sanctions, data breaches, or violations of legal requirements.

Examples of information that should be redacted include:

• Personal identifiers such as Social Security numbers or birth dates
• Financial details like bank account or credit card numbers
• Private communications covered by the attorney–client privilege
• Medical records or health-related data protected under HIPAA

One of the most common eDiscovery challenges is maintaining a balance between transparency and confidentiality. Automated redaction tools can speed up the process, but human review is still necessary to verify accuracy and context.

For instance, a legal AI system might flag names or numbers, but only an attorney can decide if they are relevant or privileged within the legal case.

Careful redaction protects both clients and opposing parties, keeping productions compliant and defensible. Every redaction decision should be logged and stored with a record of who approved it, so there is a clear audit trail for future reference.

10. Track Costs and Vendor Performance Throughout the Process

Monitoring expenses and vendor results is an often-overlooked part of the eDiscovery process, yet it has a direct impact on both budgets and case efficiency.

Each stage of discovery incurs measurable costs tied to storage, software licenses, and professional services. So, keeping a detailed record of these figures helps legal teams forecast spending, justify budgets, and identify where savings are possible in future matters.

For example, a law firm working with multiple vendors might notice that one provider charges significantly higher rates for hosting data but delivers slower turnaround times.

Tracking this performance over several projects makes it easier to decide who offers the best value. Metrics like average processing time, accuracy rates, and responsiveness can help build a clear picture of which partnerships are most effective.

Many firms now use dashboards or litigation management software to centralize cost data, automate invoices, and monitor key metrics in real time.

In other words, treating cost and performance tracking as part of the standard workflow keeps the overall eDiscovery process both predictable and efficient.

11. Regularly Update and Refine eDiscovery Policies and Technology

Finally, every organization should treat its eDiscovery policies as living documents that evolve with new data sources, laws, and legal tech software.

Some areas that should always be reviewed include:

• Backup tapes: Make sure retention schedules reflect current storage limits and recovery options.
• Preservation measures: Reassess how data is secured to avoid accidental loss or overwriting.
• Collecting ESI: Verify that approved tools and methods maintain file integrity and defensibility.
• Producing electronically stored information: Confirm that file formats and transfer protocols meet court and client expectations.

Keeping eDiscovery tools and practices updated not only supports compliance but also reduces manual work. Teams that modernize their approach are better equipped to manage complex matters efficiently.

Autodoc, the newest solution from Briefpoint, takes this a step further. It ends manual discovery work by turning productions and case files into ready-to-serve discovery responses (with Bates numbering and page-level citations) in just seconds.

Book a demo and be among the first to automate their discovery responses.

Briefpoint and the Future of eDiscovery

Strong eDiscovery practices are built through structure, collaboration, and the right technology to keep everything moving smoothly. Each stage of discovery, from locating data to preparing final productions, depends on accuracy and clear communication.

And when teams work within a defined system, discovery becomes less chaotic and more predictable.

Briefpoint helps make that happen. It replaces repetitive manual work with automation that drafts, numbers, and formats discovery responses in just minutes. The result is more time for strategy, stronger client outcomes, and less effort spent on administrative tasks.

If you’re ready to simplify discovery and see what faster, smarter document preparation looks like, book a Briefpoint demo today.